[Update 12 September, 2014: I’ve added below links to the letters of the FDLP Regional Librarians group and of the Depository Library Council (DLC). I struck out my comment about GODORT being the only group comprised of govt information librarians. JRJ]
I thought it’d be helpful to post the various letters in response to Government Printing Office (GPO) Superintendent of Documents’ recent proposal to allow Regional Depositories in the Federal Depository Library Program (FDLP) to do “e-substitution” and discard some government documents that are authenticated on GPO’s Federal Digital System (FDsys). We have commented before on this proposal (see “Why GPO’s proposed policy to allow Regionals to discard is a bad idea”). the title, as well as the choice of comic, will tell you what we think of the proposal ;-)).
But I think it’s interesting to compare the letters from the American Library Association (ALA), American Association of Law Libraries (AALL), Association of Southeast Research Libraries (ASERL), Association of Research Libraries (ARL), and ALA’s Government Documents Round Table (GODORT). All of the associations but GODORT are in favor of the proposed rule change — though AALL brings up similar issues of concern to GODORT —
but GODORT is the only group comprised wholly of practicing government information librarians working daily with this corpus. It should also be noted that GODORT’s recommendation is not strictly opposed to the proposal, but their letter says that research should be done *first* to put the community on solid ground before going forward with irreversible discards. All of the letters agree that FDsys should undergo a TRAC audit, and all agree that there remains a need for a geographically distributed “requisite number of tangible copies” of government documents — ASERL says a few as 5 – 10 copies will be sufficient, while AALL hints at a larger, as-yet-unknown number. ASERL and ARL state that the policy should be expanded to include e.g. HathiTrust content and “documents scanned by FDLP libraries and other reliable content providers.”
“The proposed policy takes steps to allow flexibility while seeking to retain the accessibility and preservation of the collections. We support this policy change as regional depository libraries must balance space constraints, staffing pressures, and increased electronic documents. Given that usage for in person retrieval of depository items has decreased, the pressure to make changes to these collections has increased. That said, ALA does not want to hinder long term preservation of government information in order to make this possible.”
They support the policy change, but raise concerns including:
–What is the “requisite number of tangible copies” and what would be their geographic distribution? As an official study has not been done, when and how would GPO make this consideration?
–How long would regional libraries need to wait after making a request to discard and what would this process entail?
They recommend a TRAC audit of FDsys be done as it will be “beneficial for its long term success to be independently audited and certified.”
AALL is generally in favor, but:
“strongly believe[s] GPO must ensure that tangible items continue to be geographically dispersed so as to meet the needs of the public and the requirements under Title 44” … and “requests further discussion about the definition of “requisite number of tangible copies.” Interestingly, they note “It is possible that law libraries may conclude that more copies of print legal materials are needed to ensure public access to the law, both current and past. It is possible that law libraries may conclude that more copies of print legal materials are needed to ensure public access to the law, both current and past.”
They also want clarification on some points, including how the Superintendent of Documents will prioritize requests to discard, and wanting a list of eligible FDsys collections which are currently authenticated and complete. They make the point that “it is possible that many regionals will request the opportunity to discard.”
“encourage[s] GPO to pursue Trustworthy Repositories Audit & Certification (TRAC) to verify FDsys’ status as a Trusted Digital Repository” and “applaud GPO for its ongoing partnership with LOCKSS-USDOCS, which helps to ensure access through its geographically distributed sites and multiple replications. We urge GPO to continue to pursue partnerships with libraries, nonprofits such as the Internet Archive and DPLA, and other institutions that can support GPO’s responsibility to provide permanent public access. Some depository libraries may also have capabilities to conduct digital deposit, and we encourage GPO to explore this option.”
“ASERL has long been concerned that the current FDLP model requires more print collections than appears to be necessary to satisfy the need for the American public’s access to FDLP content. As a result, many FDLP libraries struggle with supporting significant, unnecessarily-redundant legacy print FDLP collections, many of which go largely unused. We are encouraged to see GPO consider new ways to balance the print-electronic transition; exploring ways for Regional depositories to consider weeding portions of their legacy print content when good-quality electronic substitutes are available is a fine place to start.”
ASERL makes 7 points, including recommending “TRAC certification in the future to become a Trusted Digital Repository, to ensure electronic access to FDLP content remains reliable for the foreseeable future. This is a long-term objective; we feel TRAC certification should not delay implementation of this discard policy/process.” They also want GPO to “provide incentives for depositories to take on print retention commitments, such as providing cataloging records for legacy collections via OCLC to ease collection management responsibilities, and procuring large scale digitization of the legacy print corpus as well” … “develop means to authenticate additional content — including documents scanned by FDLP libraries and other reliable content providers” … and “identify and provide support for a non-governmental electronic repository (e.g., Hathitrust) to serve as an official supplementary access point to the growing collection of electronic FDLP content.”
“Current law, section 1912 of Title 44, authorizes regional depository libraries to manage the disposal process of government publications. Given the years of experience and best practices that have been adopted by these libraries, regional depository libraries should continue in this role in lieu of new roles for GPO. Imposing potentially new regulatory burdens on these libraries would negate the new flexibilities the proposal seeks to introduce.”
“GPO should also proceed with the TRAC review (e.g. certification and assessment) of FDsys that had been previously agreed to but not undertaken. As GPO has already decided to move forward on such a certification, this would not in any way lead to a delay in implementing the proposal…”
“…ARL very much appreciates that GPO understands electronic access is a preferred manner of access to government information for the public. To that end, we believe that the proposal as currently drafted should provide greater clarification and be expanded to a greater number of government-produced publications.”
GODORT’s letter to GPO: (note: I’m linking to FGI because the GODORT letter is posted to ALA Connect which requires a user name/password for access)
“Because the community has yet to conduct research on or come to consensus about the number of copies and geographic distribution of historic physical documents necessary to assure preservation of and access to the FDLP collection, GODORT finds that it is in the best interest of the long-term viability of the FDLP to first conduct research on the national collection before beginning to allow regional depository libraries to do any electronic substitution…”
“…In general, GPO policy changes that will result in withdrawal and discard of materials from regional collections should be based on evidence that shows that the changes, at minimum, will do no harm and preferably will provide a demonstrable benefit to public access and preservation. Prior to the establishment of any policy allowing electronic substitution for regional depository libraries, we highly recommend that substantial progress be made in assuring permanent access to tangible materials, born-digital files, and digitized surrogates of historic tangible materials…”
“…The need for FDsys, including its succession plan, to be independently audited by a trusted organization for long-term reliability under internationally-recognized standards such as TRAC becomes more pressing as reliance on its contents increases.”
Letter from the FDLP Regional Librarians. See my comments and questions below.